# HEXABROMOCYCLODODECANE

**DRAFT RISK MANAGEMENT EVALUATION** 

Prepared by the ad hoc working group on HEXABROMOCYCLODODECANE Persistent Organic Pollutants Review Committee

**April 20**  **11 Persistent Organic Pollutants Review Committee** 

2 **TABLE OF CONTENTS** Executive summary ................................ ................................ ................................ ................................ .......................... 3 1. Introduction ................................ ................................ ................................ ................................ ............................ 4 1.1 Chemical identity of the proposed substance ................................ ................................ ................................ 4 1.2. Conclusions of the Review Committee regarding Annex E information ................................ ................. 6 1.3. Data sources ................................ ................................ ................................ ................................ ............. 6 1.4. Status of the chemical under international conventions ................................ ................................ ........... 8 1.5. Any national or regional control actions taken ................................ ................................ ......................... 8 2. Summary information relevant to the risk management evaluation ................................ ................................ ....... 9 2.1. Identification of possible control measures ................................ ................................ .............................. 9 2.2. Eff icacy and efficiency of possible control measures in meeting risk reduction goals .......................... 10 2.3. Information on alternatives (products and processes) where relevant ................................ .................... 11 2.3.1 Production of high impact polystyrene (HIPS) plastic ................................ ................................ .. 13 2.3.2 Production of flame retarded textile back- coating ................................ ................................ ........ 13 2.3.3 Production of flame retarded expanded and extruded polystyrene (EPS/XPS) ....................... 13 2.4. Summary of information on impacts on society of implementing possible control measures ............... 15 2.4.1. Health, including public, environmental and occupational health ................................ ........... 15 2.4.2 Biota (biodiversity) ................................ ................................ ................................ .................. 16 2.4.3 Economic aspects, including costs and benefits for producers and consumers and the distribution of costs and benefits ................................ ................................ ................................ ............................... 16 2.5. Other c onsiderations ................................ ................................ ................................ ............................... 18 3. Synthesis of information ................................ ................................ ................................ ................................ ...... 18 3.1 Summary of risk profile information ................................ ................................ ................................ .......... 18 3.2 Summary of risk management evaluation information ................................ ................................ ............... 19 3.3 Suggested risk management measures ................................ ................................ ................................ ........ 19 4. Concluding statement ................................ ................................ ................................ ................................ ........... 20 References ................................ ................................ ................................ ................................ ................................ ...... 21**Persistent Organic Pollutants Review Committee**

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### Executive summary 1. Hexabromocyclododecane (HBCD; also HBCDD) was proposed as a POPs candidate by Norway in 200 8 . In 2010 , the 6 th meeting of the POPs Review Committee decided that HBCD is likely, as a result of its long - range environmental transport, to lead to significant adverse human health and environmental effects, such that global action is warranted. 2. HBCD was conside red by the Executive Body of the UNECE Convention on Long - Range Trans - boundary Air Pollution (LRTAP) to meet the criteria for POPs as defined under the POPs protocol. HBCD is included as part of the brominated flame retardants group in the List of Substanc es for Priority Action of The Convention for the Protection of the Marine Environment of the North - East Atlantic (the OSPAR Convention). Also the Helsinki Commission (HELCOM) has included HBCD in the list of priority hazardous substances. 3. HBCD is produced in China, Europe , Japan, and the USA. The current known annual production is approximately 23,000 tonnes per year (9,000 to 10,000 t onnes in China, 13,426 t onnes in Europe and the US). T he main share of the market volume is used in Europe . 4. HBCD has been o n the world market since the 1960s. It is used as a flame retardant additive, with the intent of delaying ignition and slowing subsequent fire growth during the service life of vehicles, buildings or articles, as well as while materials are stored. The mai n uses of HBCD are in flame - retarded expanded (EPS) and extruded (XPS) polystyrene foam insulation , with smaller scale use in textile applications and electric and electronic appliances (high im pact polystyrene/HIPS) . In textiles HBCD is used in back - coati ng s for upholstery and other interior textiles, including automotive applications. The volumes of HBCD flame retarded articles imported and exported globally is generally unknown. 5. Release of HBCD into the environment may occur during all stages of its life cycle; production and manufacturing, processing, transportation, use, handling, storage or containment, point - source discharges, migratory releases from manufactured product usage and from disposal of the substance or products containing the substance. Th e European industry has since 2008 taken actions to substantially reduce HBCD emissions from HBCD production and first line use. 6. Emissions of HBCD can be reduced in production of HBCD, in processes where HBCD or articles containing HBCD are used, and duri ng the waste management phase. Emission control techniques at the production sites alone will not be efficient in solving the problem HBCD is posing for the environment and health, since there are diffuse emissions and releases to the water reserves and se wage systems from products containing HBCD. Wastes containing HBCD represent a large source of releases and increasing amounts of HBCD - containing wastes in landfills and other locations could be a long - term source of HBCD emissions. Wastes containing HBCD include production wastes, insulation boards, building and renovation wastes, and from other less - commonly used applications such as electrical and electronic products and textiles. The process of remodelling and demolition of buildings suggests that HBCD emissions are likely to continue in the future from the installed amount of materials containing HBCD . 7. A number of alternative fire retardants are available to replace HBCD in high - im pact polystyrene (HIPS) and textile back - coating . However, there appear t o be no drop - in chemical alternatives for flame - retarded EPS/XPS products in all regions. In the USA an alternative chemical flame retardant is used in the production of EPS, but not in Europe. 8. Many countries have set standards for building materials with regards to their contribution to fire. Consequently, inherently flammable materials must be treated with a flame retardant to meet certain fire performance criteria, which are required in the country regulations for a specific use. In some countries HBCD h as effectively already been phased out. In those countries the fire safety regulations do not require the treatme nt with a flame retardant. The same level of fire safety is achieved by alternative mean s that are technically feasible and also commercially available. HBCD phase out could include flame retardant substitution, resin/material su bstitution and product redesign . 9. HBCD is an intentionally produced industrial chemical. Under the Convention, the most adequate control measure is listing in Annex A. To allow for certain time - limited critical uses of HBCD a specific exemption for use of HBCD , could be given together with detailed conditions for HBCD production and uses . Stockpiles and waste containing HBCD wo uld be subject to the wa ste provisions in Arti cle 6.**Persistent Organic Pollutants Review Committee**

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### 1. **Introduction** 10. On June 18th 2008, Norway, as a Party to the Stockholm Convention, submitted a proposal to list the brominated flame retardant hexabromocyclododecane (HBCD; also HBCDD) as a possible Persistent Organic Pollutant (POP) under Annex A of the Convention (UNEP/POPS/POPRC.5/INF/16 ) . **1.1 Chem** **ical identity of the proposed substance**  11. Commercial HBCD is a white solid substance. Producers and importers have provided information on this substance under two different names; h exabromocyclododecan e (EC Number 247 - 148 - 4, CAS number 25637 - 99 - 4) and 1,2,5,6,9,10 - hexabromocyclododecane (EC Number 221 - 695 - 9, CAS number 3194 - 55 - 6). The structural formula of HBCD is a cyclic ring structure with Br - atoms attached ( Table 1 ). The molecular formula of the com pound is C 12 H 18 Br 6 and its molecular weight is 641 g/mol. Depending on the manufacturer and the production method used, technical HBCD consists of 70 - 95 % γ - HBCD and 3 - 30 % of α - and β - HBCD ( European Commission 2008; Nordic Council of Ministers (NCM) 2008 ) . Each of these stereoisomers has its own specific CAS number i.e. α - HBCD, CAS No: 134237 - 50 - 6 ; β - HBCD , CAS No: 134237 - 51 - 7 ; γ - HBCD , CAS No: 134237 - 52 - 8. Two other stereoisomers, δ HBCD and ε–HBCD have also been found in technical HBCD in low concentration s . Further information pertaining to the chemical identity of HBCD is listed in Table 2 and may be found in the supplementary information to the Risk Profile on HBCD ( UNEP/POPS/POPRC.6/INF/25 ) . **Table 1.**  **Inform ation pertaining t**  **o the chem ical identity of H**  **BCD Chemical structure**  **Structural form ula of HBCD**  **1 :**  1 Structural formula for 1,2,5,6,9,10 - HBCD, i.e., CAS no 3194 - 55 - 6. Note that CAS no 25637 - 99 - 4 is also used for this substance, although not correct from a chemical point of view as this number does n ot specify the positions of

the bromine atoms. As additional information, the structures and CAS numbers for the diastereomers making up 1,2,5,6,9,10 - HBCD are given below , although these diastereomers always occur as mixtures in the technical product. **Chiral components of comm**  **ercial HBCD:** B r

B r B r B r

B r B r alpha - HBCD CAS No: 134237 - 50 - 6 B r

B r B r B r

B r B r

beta - HBCD CAS No: 134237 - 51 - 7 gamma - HBCD CAS No: 134237 - 52 - 8

B r B r B r B

r B r B r**Persistent Organic Pollutants Review Committee**

5 **Table 2. Chemical identity Chemical identity**  **Chemical Name:** Hexabromocyclo dodecane and 1,2,5,6,9,10 - hexabromocyclododecane **EC Number:** 247 - 148 - 4; 221 - 695 - 9 **CAS Number:** 25637 - 99 - 4; 3194 - 55 - 6 **IUPAC Name:** Hexabromocyclododecane **Molecular Formula:** C 12 H 18 Br 6 **Molecular Weight:** 641.7 **Trade names/ other synonyms:**  C yclododecane, hexabromo; HBCD; Bromkal 73 - 6CD; Nikkafainon CG 1; Py roguard F 800; Py roguard SR 103; Py

roguard SR 103A; Py

rovatex 3887; Great Lakes CD - 75PTM; Great Lakes CD - 75; Great Lakes CD75XF; Great Lakes CD75PC (compacted); Dead Sea Bromine Group Ground FR 1206 I - LM; Dead Sea Bromine Group Standard FR 1206 I - LM; Dead Sea Bromine Group Compacted FR 1206 I - CM. **Stereoisom ers and**  **purity of commercial products:**  Depending on the producer, technical grade HBCD consists of approximately 70 - 95% γ HB C D and 3 - 30 % of α - and β - HBCD due to its production method ( European Commission, 2008 ). Each of these has specific CAS num bers. Two other stereoisomers, δ - HBCD and ε– HBCD have also been found by Heeb et al. (2005) in commercial HBCD in concentrations of 0.5 % and 0.3 %, respectively. These im purities are regarded as achiral at present. According to the same authors, 1,2,5, 6,9,10 - HBCD has six stereogenic centers and therefore, in theory, 16 stereoisomers could be formed. 12. HBCD has been on the world market since the 1960s. Production has been reported in China, Europe, Japan, and the USA. The current known annual productio n is approximately 23 , 000 t onnes per year (9,000 to 10,000 t onnes in China, 13,426 t onnes by

the BSEF member companies in Europe and the US). Japanese production data is not available. No information on production in other countries or by non - BSEF member companies was received. 13. Based on responses from Parties and Observers , it appears that the main consumption and use of HBCD takes place in Europe. According to the global demand reported by the industry in 2001, more than half of the market volume (9,500 o f 16,500 tonnes) was used in Europe. Total global demand for HBCD increased over 28% by 2002 to 21,447 tonnes, and rose again slightly in 2003 to 21,951 tonnes (BSEF 2006). In the US the sum of manufactured and imported HBCD is reported to lie between 4,54 0 to 22,900 tons in 2005 (US EPA 2008) . The total volume of HBCD used in the EU was estimated to be about 11,580 tonnes in 2006. The demand of HBCD within the EU is bigger than the production there and the net import to the EU was expected to have been aro und 6,000 tonnes in 2006 (ECHA 2008a). The authorities in Japan have reported the sum of domestic production and import of HBCD to be 2, 8 44 tonnes in 2008 and 2,613 tonnes in 2009 . Several other national authorities report an import of HBCD as a pure compo und or in products; Canada (100 - 1,000 tonnes), Australia (<100 tonnes), Poland (500 tonnes imported from China annually), Romania (185 tonnes) , and Ukraine (BSEF 2011, UNEP/POPS/POPRC.6/13/Add.2 ). Available information suggest s that use of HBCD may be risi ng (ECHA 2008a) . T here is also evidence that HBCD may be replacing some polybrominated diphenyl ether (PBDE) flame retardants (notably the commercial d ecabromodiphenyl e ther formulation) (Environment Canada 2010a) . 14. HBCD is used as an additive flame retardant, with the intent of delaying ignition and slowing subsequent fire grow th during the service life of vehicles, buildings or articles, as well as while materials are stored (BSEF 2010 , see UNEP/POPS/POPRC.6/13/Add.2 for overview). The main uses of HBCD gl obally are in flame - retarded expanded (EPS) 1 and extruded (XPS) 2 polystyrene foam insulation ( mo re than 95% in Europe ), whi le the use in textile applications 3 and electric and electronic appliances (high impact polystyrene/HIPS) 4 is of a smaller scale ( BSE F 2011, 1 0.5 - 0.7 % HBCD w

/w 2 0.8 - 2% HBCD w

/w 3 10 - 15% HBCD w/w 4 1 - 7 % HBCD w/w**Persistent Organic Pollutants Review Committee**

6 UNEP/POPS/POPRC.6/13/Add.2 and references therein e.g. ECHA 2008a, US EPA report, OECD 2007, INE SEMARNAT 2004, Lowell Center For Sustainable Production (LCSP 2006), BSEF 2010). The use of HBCD in insulation boards started in the 1980s. HBCD is use d in textile back - coating in upholstery furniture and other interior textiles, including automotive applications (Japan 2011, LCSP 2006) . Some other minor uses have also been reported by KEMI (2006) . 15. Based on the responses from the Parties and Observers and ECHA (2009), the volumes of im port and export of HBCD in flame retarded articles is generally unknown. Polystyrene foams and t extiles are usually tailor made for the local market, and the main share of the production is for local consumption, and not exported (SWEREA 2010 , BSEF 2011 ). **1.2. Conclusions of the Review Committee regarding Annex E inform**  **ation** 16. At its sixth meeting in October 20 10, the POPs Review Committee evaluated the draft risk profile for HBCD in accordance with Annex E ( UNEP/POPS/POPRC. 6/13 ) and adopted this (UNEP/POPS/POPRC.6/13/Add.2). The POPRC decided that , “in accordance with paragraph 7 (a) of Article 8 of the Convention, hexabromocyclododecane is likely, as a result of its long range environmental transport, to lead to significant adverse human health and environmental effects such that global action is warranted”. The Committee also decided to establish an ad hoc working group to prepare a risk management evaluation that includes an analysis of possible control measures for hexabr omocyclododecane in accordance with Annex F to the Convention for consideration at its next meeting . **1.3. Data sources**  17. This risk management evaluation was developed using Annex F information submitted by Parties and observers, including the industry usin g and producing HBCD. 18. Sixteen Parties and country O bservers submitted information (Brazil, Burundi, Canada, China, Costa Rica, Czech Republic, Ecuador, Finland, Germany, Japan, Nigeria, Norway, Mauritius, Romania, and Sweden). Five non governmental O bserv ers submitted information

– Bromine Science and Environmental Forum (BSEF), PlasticsEurope/Exiba, Instituto do Meio Ambiente (IMA) Brazil, Extruded Polystyrene Foam Association (XPSA) and Canadian Plastics Industry Association (CPIA) as well as the International POPs Elimination Network (IPEN). All submissions are available on the Convention web site . 19. Brazil reported it does not produce HBCD, and noted the lack of information on emissions and use. In general HBCD is used in electronic equipment, automotive and textiles production. Brazil also provided extensive information on alternatives to HBCD and HBCD containing products. 20. Burundi report ed it does not produce HBCD. Burundi highlighted the lacking of capacity for monitoring and control of chemicals and wa ste , and noted the need for capacity - building in emergency services, environmentally sound destruction and recycling technologies . 21. Ecuador reported that HBCD is imported into the country only in articles, not as a substance. 22. Canada reported that HBCD is u sed in flame - retarded PS foams and textiles. In Canada HBCD is used in PS foams in lower concentration s (0.5 - 1%) than in Europe. Canada also noted the potential for brominated dioxin and furan emissions related to uncontrolled burning of HBCD containing articles. HBCD has been monitored across Canada in landfill leachate since 2009, with varying detection frequency . HBCD has also been mo nitored in surface water, sediment, air, aquatic biota and wildlife, since 2008. HBCD has been detected in human blood, br east milk, dust and am bient air. 23. China provided information on production of HBCD in the country and supported emission control, improved wa ste management and HBCD substitution as potential control measures. China also noted that the risks of alternatives to the environment and human health were not yet addressed. 24. Costa Rica and Mauritius reported no production . Costa Rica also noted the lack of information on HBCD use in the country impeding the identification of alternative products. 25. The Czech Republic reported on its ambient air monitoring activities. HBCD isomers were released in the air during storage, manipulation of the mixture and during the PS production process in 2010. The concentrations inside and outside the production facility were hundreds o f ng/m 3 . HBCD was not found in human milk, but in 10% of the liposuction samples. Czech Republic also pointed out that there is no information on import and export of HBCD in the EU. 26. Finland submitted information on emissions and emission control measure e ffectiveness at a recently closed EPS production facility. The results confirm the need to address production waste (HBCD packages) and emissions to air,**Persistent Organic Pollutants Review Committee**

7 sediment and waste water ( from poly styrene beads). 11 % of the EPS produced in the country is flame re tarded with HBCD. Fire safety regulations do not require use of flame retardant in insulation boards. 27. Germany noted that the use of EPS/XPS insulation boards without flame - retardant is not allowed according to the German fire safety regulations and that th ere is currently no drop - in chemical substitute for HBCD in this use. Germany expressed the need for a time limited exemption for HBCD use in EPS/XPS production. They also noted the presence of alternative insulation materials to EPS/XPS and that product r edesign is technically feasible. 28. Japan reported use of HBCD in XPS , EPS, automotive textile s , and curtain/blind production. In new car - mo dels HBCD fabrics are not used anymore, but the demand for fabric used in older models will continue for some time. XP S , as well as curtain and blinds producers are working towards reducing or eliminating HBCD use, but no available chemical alternatives have been identified. In Japan, EPS waste is collected and recycled as fuel, i.e. RPF (Refuse Paper and Plastic Fuel) , and other products in effective recycling systems . 29. Nigeria reported no production, but use of HBCD in EPS, XPS, HIPS and polypropylene fibre. Nigeria provided information on alternatives to HBCD in certain uses and supported substitution of HBCD with susta inable flame retardants, use of product stewardship programs to minimize emissions , and introduction of regulations to promote search for the alternatives. Nigeria also stressed the importance of ensuring the safety of the alternative chemicals and buildin g laboratory capacity for chemical measurements. 30. Norway

has prepared a risk management exploration proposal to the UNECE CLRTAP POPs Task Force on HBCD (Exploration of management options for Hexabromocyclododecane (HBCD) . Fire regulations allow use of EPS /XPS insulation boards without flame retardants in Norway if thermal barriers are used. The Norwegian producers provide EPS without flame retardants to the Norwegian market. The import ed HBCD, approximately 22 t per year, is exported to the EU in EPS. Ther e are no other registered uses of HBCD in Norway. A lternatives other than HBCD are used fo r textiles and furniture. There is no information on amounts of HBCD in imported products and articles. Norway stressed the importance of releases from waste, especia lly insulation materials. HBCD has been found in the environment both close to EPS production sites and in the remote regions in the Norwegian Arctic. 31. Romania reported use of HBCD in EPS and XPS production. The annual use from 2009 was 134 t onnes for EPS and 50 t onnes for XPS production. With regards to the waste management implications, Romania noted milling and recycling of polystyrene waste. 32. Sweden expressed the need to achieve fire safety without flame retardants by use of alternative materials and pro duct designs, due to the inherent hazardous properties of many flame retardants , and highlighted that a lternative solutions are also available. HBCD use in insulation materials is very small in Sweden as fire safety standards do not require EPX/XPS to be f

lame retarded. HBCD is being monitored by Swedish contaminant monitoring programmes in marine biota, human milk and ambient air. Due to negligible domestic use, the Swedish environmental levels are heavily dependent on HBCD control measures in other countries. 33. Bromine Science and Environmental Forum (BSEF) submitted information on production and uses of HBCD, noting that the only production facility in Europe had reduced its total HBCD emission s to the environment to less than 2 kg a year. BSEF was also con cerned over the effects of potential HBCD restrictions on the market and producers, and expressed the industry commitment to continue research to find a chemical alternative to HBCD. 34. Plastics Europe/Exiba , representing the HBCD users in the PS industry , r eported th at HBCD is used in 0.7% content in EPS and an average of 2% in XPS. Plastics Europe/Exiba also highlighted the successful emission reductions programmes (VECAP/SECURE) in 2006 - 2009, w here potential emissions from first line users were reduced by 85 %. To ensure smooth transition once an alternative is available, the industry intends to apply for REACH authorization for the use of HBCD in polystyrene in Europe, before the EU chemicals policy ban takes effect in 2015 (see para 40) . 35. IPEN highlighted the need to ban HBCD to reduce the levels in the environment and noted the availability of alternative materials to replace EPS/XPS. Elimination of flame retardant use in applications where no fire hazard exists could be a starting point (underground appli cations, non - combustible surfaces, thermal barriers). IPEN also noted the wide availability of chemical and non - chemical alternative flame retardants for use in insulation noting that the chemical substitutes also may have hazardous properties. Special att ention should be paid to waste containing HBCD and emissions from burning HBCD containing materials. 36. The North American XPS Industry (XPSA and CPIA) noted that the U.S. and Canadian building codes contain provisions to limit ignition and burning and th at i nsulation i s important to reduce CO 2 emissions . The use of a flame retardant such as HBCD wa s reported necessary for XPS to meet the U.S. requirements of ASTM C - 578 and achieve the International Building Code and International Residential Code class A des ignation for flame spread and smoke development per ASTM E - 84. U se of a flame - retardant such as HBCD also enables XPS to meet the requirement s of CAN/ULC S701 and CAN/ULC S102.2 , of the 2005 National Building Code of Canada for foamed plastics in non combu stible construction. The HBCD concentration in XPS produced in the US and Canada is lower than in Europe, on**Persistent Organic Pollutants Review Committee**

8 average 0.8% by

w eight . XPSA and CPIA noted that in production of flame retarded XPS, HBCD releases are possible during transfer from the original packaging to the feeder at the start of the process, in disposal of packaging materials, and during process upsets. **1.4. Status of the chem** **ical under international conventions** 37. HBCD is included as part of the brominated flame retardants group in the List o f Substances for Priority Action of The Convention for the Protection of the Marine Environment of the North - East Atlantic (the OSPAR Convention). The OSPAR Convention is made up of representatives of the Governments of 15 Contracting Parties and the Europ ean Commission. Also the Helsinki Commission (HELCOM) has included HBCD in the list of priority hazardous substances. 38. In December 2009, HBCD was considered by the Executive Body of the UNECE Convention on Long - Range Trans - boundary Air Pollution (LRTAP) bas ed on a technical review (ECE/EB.AIR/WG.5/2009/7) to meet the criteria for POPs as defined under the POPs protocol. In 2010 the possible management options for HBCD were assessed to give a basis for later negotiations. The negotiations are expected to be i nitiated in December 2011. **1.5. Any national or regional control actions taken**  39. Many countries have set standards for building materials with regards to thei r contribution to fire. Consequently, inherently flammable materials must be treated with a flame r etardant to meet certain fire performance criteria, which is required in the country regulations for a specific use. Fire protection requirements for certain articles are laid down in acts, ordinances and regulations as well as in standards. In the legislation, the requirements are normally specified in general terms. To demonstrate that the requirements are met, there are prescribed verifiable criteria, w hich standardisation bodies such as ISO, CEN and UL often have helped to develop (KEMI 2006) . 40. In Europe fire test methods have been harmonised and classification of reaction to fire performance for construction products , excluding floorings , are based on four fire test methods: the non - combustibility test EN ISO 1182, the gross calorific potential test EN I SO 1716, the single burning item (SBI) test EN 13823, and the ignitability test EN ISO 11925 - 2. Building products are divided into seven classes on the basis of their reaction - to - fire properties. (SWEREA 2010). In the U.S. there are numerous regulations an d standards that apply to insulation used for the building industry. These regulations and standards may exist at the national, state, county, or municipal level (L SCP 2006) . 41. There are requirements in some countries regarding the use of flame retardant s in PS foam for insulation. Fire safety regulations require that f lame retardant must be used in Canada, Austria, Czech Republic, Germany, Hungary, Netherlands, Slovakia, Slovenia, and Switzerland in all building applications, irrespective of the use. Moreove r, flame retardants are used to reduce fire risk for warehouses containing EPS before use in buildings/packaging. Fire regulations and international standards govern the fire safety of polymer applications, but they do not require the use of a certain flam e retardant. In Denmark and Iceland flame retarded EPS is required for use in buildings. In Italy, Portugal and UK flame retarded PS foams are generally used according to the industry. Flame - retarded PS foam may be used in some building applications in Finland, Norway, and Sweden, although it is not required. In Sweden, the industry has voluntarily withdrawn HBCD containing products from the market, which is possible because alternative construction techniques can be used , even with EPS applications . 42. The E U’s Directive on Waste Electrical and Electronic Equipment (WEEE) ( 2002/96/EC ) requires the removal of plastics containing brominated flame retardants and of printed circuit boards from electrical and electronic equipment prior to recovery and recycling. 43. HBCD has been identified by the EU as a Substance of Very High Concern (SVHC), meeting the criteria of a PBT (persistent, bioaccumulative and toxic) substance pursuant to Article 57(d) in the REACH regulation ( ECHA 2008b ). In February 2011 HBCD was include d in the European Chemicals Agency (ECHA) list of substances subject to authorisation under REACH . Taking effect in 2015 , HBCD can no longer be used without authorisation. A proposal on classification and labelling of HBCD as a possible repro ductive toxic substance wa s made within the EU (Proposal for Harmonised Classification and Labelling, Based on the CLP Regulation (EC) No 1272/2008, Annex VI, Part 2 Substance Name: Hexabromocyclododecane Version 2, Sep. 2009) (KEMI 2009). The EU risk assessment committ ee (RAC ) is of the opinion that HBCD should be classified as suspected to damag e fertility or the unborn child (Repr.2 HR361 ), and may cause harm to breast - fed children (Lact. H362) (RAC 2010) . 44. In Ukraine HBCD is registered on the hazardous chemical list based on health effects. 45. In Japan HBCD h as been designated as a Monitoring Chemical Substance because o f its persistence and high bio - accumulation under the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. (commonly r eferred to as the Chemical Substances Control Law "CSCL"). In September 2010, Japanese Ministers of Health, Labour and Welfare, and of Economy, Trade and Industry and of the Environment instructed persons operating**Persistent Organic Pollutants Review Committee**

9 the business of manufacturing or importin g HBCD to conduct an Avian Reproduction Test (OECD Test Guideline 206) and to report the results thereof by the end of March 2014 under CSCL. 46. In the USA, the EPA anticipates proposing a significant new use rule (SNUR) under section 5(a)(2) of the Toxic Sub stances Control Act (TSCA) for the use of HBCD in consumer textiles. Such a proposal would indicate that EPA believes such use would constitute a significant new use. The SNUR would require persons who intend to manufacture, import, or process HBCD for th e designated significant new use to notify EPA at least 90 days before commencing such use. The required notification would provide the EPA with the opportunity to evaluate the intended use and, if necessary, to prohibit or limit that activity before it o ccurs. 47. A proposal for a national ban of HBCD is currently under consideration by the Norwegian Ministry of the Environment (Norway 2011) . Canada is currently undertaking a risk assessment of HBCD and will be considering control measures when that assessme nt has been completed, which is expected in 2011. 

### 2. **Summary information relevant to the risk management evaluation** 48. HBCD may be released to air, water, soil and sediment. Release of HBCD into the environment may occur during production and manufacturing, processing, transportation, use, handling, storage or containment, point - source discharges, migratory releases from manufactured product usage and from disposal of the substance or products containing the substance. In Canada, HBCD has been known to be di scharge d into various tributaries, watersheds, rivers and lakes resulting in increased levels in sediments, surrounding soils and biota ( Environment Canada 2010 b ). 49. Releases of HBCD to the environment from HBCD production have been considered small in the EU, with only one production facility. In the EU it was estimated that about 3 kg a year are released from the workplace plus a further 2 kg to air and 0.1 kg to waste water. The estimated releases of HBCD to the environment during the manufacture and formulation of HBCD containing products were 41 kg to air, 60 kg to waste water and 35 kg to surface water per year in the EU RAR (ECHA 2008a). The release of HBCD from products during end use is small. Some dust containing HBCD will be released during the inst allation of EPS or XPS insulation and ultimately during the refurbishment or demolition of buildings containing these products. The estimated annual release to the environment was 530 kg to air, 1,140 kg to waste water and 560 kg to surface water. According to the EU RAR, the end use releases to waste water and surface water are dominated by textile coating s . The use of HBCD in textiles is believed to have fallen substantially in recent years. The quantities of waste product s sent for disposal are uncertain and it was also noted that estimated releases of HBCD during the consumer use of products are highly uncertain (ECHA 2008a). 50. Releases from waste disposal are difficult to estimate because of the long lifetime of XPS and EPS once installed in buildings (p otentially up to 100 years) combined with an increasing trend towards the recycling of electrical equipment. Solid waste containing HBCD may be scrap materials generated during processing operations, particulates released through aging and wear of end products, and disposal of products at the end of service life. Products and materials in landfill sites will be subject to weathering, releasing HBCD particulates primarily to soil, and to a lesser extent, to water and air (Environment Canada 2010b) . 51. HBCD phas e - out could include flame retardant substitution, resin/material substitution and product redesign (LCSP 2006). In addition, re - evaluating fire - safety requirements e.g. in applications where fire hazard is absent (such as underground applications) or otherwise eliminated would reduce the need for flame - retarded insulation materials. Emissions of HBCD can be reduced in processes where HBCD or articles containing HBCD are used, and during the wa ste management phase. In Sweden, the industry has voluntarily withdrawn HBCD containing products from the market, which is possible because alternative construction techniques can be used. **2.1. Identification**  **of possible control m easures**  52. The objective of the Stockholm Convention (Article 1) is to protect human health and the environment from persistent organic pollutants. Under the Convention this may be achieved by listing HBCD in Annex A, with or without specific exemptions, possibly accompanied with detail ed actions for production and certain uses of HBCD . 53. In the Annex F process, a number of HBCD uses have been identified by Parties and O bservers. For many of the uses alternatives are already available and currently used in many countries. These uses include production of high im pact polystyrene (HIPS) plastic and pr oduction of flame retarded textile back- coating . Alternative flame retardants to HBCD in production of flame retarded expanded polystyrene are being developed and used in some regions, but they are not suitable for all production processes . Also, their hea lth, safety, and environmental properties may not be well known . However, alternative insulation materials and technical solutions to EPS/XPS are already widely used as well as alternative construction methods . These uses and the potential substitutes will be further described in section 2.3. below .**Persistent Organic Pollutants Review Committee**

10 54. Emission reduction measures and use of best practices would be required in the production and manufacture for potential specific exemptions and exempted use s in order to reduce HBCD releases to the environment f rom these exempted uses. Significant reduction in estimated total emissions from production and first line users has been reported by the industry in Europe following voluntary measures. 55. In accordance with Article 6(1)(d)(ii), HBCD containing products (EPS , XPS, HIPS, textiles) should be managed in an environmentally sound manner and disposed of in such a way that their POPs content is destroyed. This will require separation of HBCD containing articles from others upon becoming waste , and the prevention of inappropriate waste management practices leading to recycling of the POP content . **2.2. Efficacy and efficiency of possible control m**  **easures in meeting risk reduction goals**  56. Listing HBCD in Annex A of the Convention without exemptions would effectively reduce the releases of HBCD. This would require either introducing alternative building techniques or insulation material to achieve fire safety in construction, or the industry phasing in an alternative to HBCD. 57. Based on the submissions from Parties and Obs ervers , there is currently a need for flame retarded insulation materials due to country - specific fire safety requirements in some countries . However, the safety requirements do not identify any specific flame retardant substances or groups of flame retard ant substances that have to be used. Some countries have already phased out HBCD in the absence of a substitute chemical flame retardant indicating that there are alternative materials and techniques available on the market already . However, no viable rep lacement to HBCD is yet available commercially for flame retarded EPS and XPS production . 58. Emission control techniques at the production sites alone will not be su fficient to solv e the problem HBCD is posing to the environment and to health, since the diff use emissions and releases to the water reserves and sewage systems from the use and machining of products containing HBCD, as well as releases when becoming waste also is of significant concern. 59. In addition to listing HBCD in Annex A, waste management me asures for materials in use should be introduced to ensure environmentally sound management of HBCD containing insulation materials, plastics, and textiles at the end - of - life stage. This would require identifying materials in which HBCD has been added when buildings are renovated or dismantled to facilitate destruction of the POP content in the waste and to prevent inappropriate management practices leading to recycling or landfilling the POP content. Recycling of HBCD can be significant. According to the Swiss substance - flow analysis , the proportion of HBCD recycled is higher than for material containing other brominated flame retardants , and the recycling percentage of HBCD used in EPS insulation was expected to rise from 30% in 2005 to 60% in 2010 (Geopartner 2007) . In the EU in 2007 , the share of EPS wi th flame retardant was 60% of the total EPS demand , and the share of XPS with flame retardant 92% of the total XPS demand (PlasticsEurope/Exiba 2011). In two Swiss studies on electronic and electrical appl iances, vehicles and building materials, HBCD was found in 2% and 6% of the studied plastic component samples (BUWAL 2004, BFR 2010 - 486 and 214 samples respectively). Another recent Swiss WEEE study, however, did not find HBCD in any of the 53 samples analysed (EMPA 2010). 60. Recycled products containing HBCD, including EPS and XPS boards, are potential sources of emissions in the same way as virgin products. Recycling operations for recovery of metals or plastics in electronic products and vehicles are po tential sources as well. In controlled waste streams parts containing HBCD could be sorted out, but this will not always be technically feasible in the waste stream. Use of label l ing of products or parts of products could be a valuable help in the process ( KEMI 2006 ). 61. EPS has an estimated service life of approximately 30 - 100 years and collecting and recycl ing used EPS may be hindered due to difficulties in separating EPS containing HBCD from others . Some EPS can be recycled and used for the manufacture of b ricks where the polystyrene is gasified and leaves a cavity in the center of the brick. In this process HBCD is destroyed. However, i t is difficult to separate the HBCD treated PS and HIPS from their HBCD - free counterparts. This greatly complicates the separation of recyclable materials. 62. Controlled i ncineration is one way to dispose of PS foam containing HBCD (CEFIC 2011, ECHA 2008 a) . The flame retardant decomposes in the incineration plant process . In a co - com bustion study in a high temperature pilot fac ility (>900°C), the foam added substantially to the Br content in the incinerator, but did not appear to add significantly to the overall hazard of raw gas or emissions (APME). Experimental evidence confirms that under some conditions HBCD and products co ntaining HBCD form and may release polybrominated dibenzo - p - dioxins (PBDD) and dibenzofurans (PBDF) during burning , even in state of the art municipal solid waste incineration facilities (APME, NCM 2004) . However, PBDDs and PBDFs formed from HBCD waste wi ll likely be destroyed by the very high operating temperatures and controlled operating conditions em ployed in state of the art incinerators. T he incineration efficiency and the operating conditions of the flue gas treatment systems are of great importance to the resulting**Persistent Organic Pollutants Review Committee**

11 emissions of dioxins (NCM 2004). Hence, there is potential for the release of these substances from uncontrolled burns and accidental fires, py

rolysis/gasification plants, recycling processes, and from incinerators that are not functionin g well (Weber and Kuch 2003). Desmet et al. (2005) also documented the formation of bromophenols, known precursors of polybrominated dibenzodioxins and dibenzofurans, during combustion of flame - retarded extruded polystyrene containing HBCD . Bromophenol fo rmation seemed to be inherent to the flame retardant mechanism of HBCD. The study did not investigate the formation of brominated dioxins and furans but noted that it was highly probable that various brominated dioxin isomers would be formed from bromophen ols. 63. State of art incineratio n with energy recovery is expected to be more widely available in the coming years, hence diverting HBCD containing materials from landfill. However, currently i n many countries landfilling is the most common way of waste disp osal, leading to HBCD containing waste accumulati ng in the landfills. **2.3. Inform**  **ation on**  **alternatives (products and processes) where relevant**  64. The POPRC has agreed that HBCD is a POP due to its long - range environmental transport and significant adverse human health and environmental effects such that global action is warranted ( UNEP/POPS/POPRC.6/13/Add.2 ) . The target or aim of any risk reduction strategy for HBCD should be to reduce and eliminate emissions and releases taking into consideration the indicative list in Annex F including technical feasibility of possible control measures and alternatives, the risk and benefits of the substances and their continued production and use. In considering any strategy for a reduction in such risks, it is important t o consider the availability of substitutes in the sectors of concern. In this regard, the replacement of HBCD by another chemical or non - chemical alternative needs to take account of factors such as:  technical feasibility (practicability of applying an a lternative technology that currently exists or is expected to be developed in the foreseeable future )  costs, including environmental and health costs  risk (safety of the alternatives)  availability and accessibility 65. A discussion of the availability and s uitability of substitutes of HBCD is provided below . 66. There are technical ly feasible and commercial ly available alternatives to different uses of HBCD on the market , although not for EPS production in Europe . They include flame retardant substitution, resi n/material su bstitution and product redesign . Several of them are halogen - free and are therefore considered to be better alternatives for the environment and health in the evaluations done (ECHA 2009, SWEREA 2010, KLIF 2010) (Table 3) . However, their other risks may not have been fully studied.**Persistent Organic Pollutants Review Committee**

12 Table 3. Summary table of technical ly feasible and commercial ly available halogen - free alternatives to the use of HBCD (based on SWEREA 2010). Polymer materials Applications Alternative chemicals Alternative mate rial and product redesign HIPS Housings of

electronic products Wiring parts Arylphosphates such as:

Resorcinol bis (biphenyl phosphate) Bis phenol A bis (biphenyl phosphate) Polymeric biphenyl phosphate Diphenyl cresyl phosphate Triphenyl phosphate Alloys of PPE/HIPS 5 treated with halogen free flame retardant alternatives

EPS & XPS Insulation of

foundatio n, walls and ceiling s Ground deck , parking deck etc . No halogen free ‘ drop in ’

replacement chemicals commercially available at present for all productio n processes and regions EPS and XPS with out FRs, using thermal barriers Phenolic foams Blankets (fiber batts or rolls) that may contain rock wool, fiber glass, cellulose or polyurethane foam Polyester batts Loose fills that may contain rock wool, fiber gla ss, cellulose or polyurethane foam Textile back coatings Protective

clothing Carpets Curtains Upholstered fabrics Tents Interior in public transportation Other technical textiles Intumescent systems 6 that

contain: a dehydrating component, such as ammonium

poly phosphate (APP) a charring component, such as pentaerythritol (PER) a gas source, often a nitrogen component such as melamine

5 PPE/HIPS: alloy of poly phenylene ether and high impact polystyrene 6 Economical viability has been questione d (BSEF 2011).**Persistent Organic Pollutants Review Committee**

13 **2.3. 1**  **Production of high im** **pact polystyrene (HIPS) plastic**  67. A number of alternative fire retardants are available to r eplace HBCD in HIPS (Table 3) . They are all require d to be used at considerably higher loadings (ECHA 2009) . Deca - BDE has been widely used in HIPS and also in electronic wire insulation but may not be suitable for use as a substitute for HBCD due to conce rns about its impact on human health and the environment as well as debromination to components of PentaBDE and OctaBDE . In the EU, the introduction of the RoHS Directive phased out the use of Deca - BDE. In the US the industry is voluntarily withdrawing D eca - BDE from most uses by 2013. Other chemicals that can be used as alternatives to HBCD in HIPS include both halogenated flame retardants used in conjunction with antimony trioxide (ATO) and halogen - free organic aryl phosphorus compounds. Halogenated fl ame retardants may also increase the toxic ity of the emissions from fire ( Dioxin 2010). Nevertheless, since HBCD is not widely used in HIPS, it may be reasonable to assume that the alternative flame retardants on the market are technically and economicall y feasible. 68. In electrical products HIPS can be replaced by various alternative materials, including blends of polycarbonate / acrylonitrile butadiene styrene (PC/ABS), polystyrene / polyphenylene ether (PS/PPE) and polyphenylene ether / high im pact polystyrene (PPE/HIPS) without flame retardants or with the use of non - halogenated flame retardants (Brazil 2011, DEPA 2010) . T hese co - polymer blends have higher impact strength and are more resistant to burning because they form an insulating char foam surfac e when heated (DEPA 2010) . **2.3. 2**  **Production of flam**  **e retarded textile back** **- coating**  69. The typical concentration of HBCD in textile applications is high compared to other applications, 6 to 15% in a polymer (CEFIC/EFRA 2006). Several chemicals may be used as drop - in alternatives for HBCD in textile applications. For textile backing, alternatives to HBCD include deca - BDE, chlorinated paraffins and ammonium polyphosphates (ECHA 2009). Deca - BDE is not readily biodegradable, and has low bioaccumulation potential in the environment. Long chain chloroparaffins are reproductive toxicants to humans, show chronic toxicity with effects o n liver and kidneys , and are potential carcinogens (ECHA 2009). 70. It is important to note, that flame - retardant use i n textile s can be avoided if the material is non flammable , such as wo ol. It can also be used as barrier materials in furniture (Norway 2011) . 71. According to the submission from Japan HBCD has been replaced in fabrics used in ne w car mo dels. However, the demand for fabrics that contain HBCD will continue for some time as such fabrics continue to be used in older mo dels (Japan 2010) . **2.3.3 Production of flam**  **e retarded expanded and extruded polystyrene (EPS/XPS)** 72. According to the European industry there are currently no commercially o r technically viable drop - in chemical alternatives to HBCD as a flame retardant in polystyrene foam. This is b ecause alternative chemical flame retardants im pair the structure and properties of the foam, making it unsuitable for use (ECHA 2009 , BSEF 2011 ). However, alternative halogenated flame retardants are commercially available in the USA for EPS, where the production process used is different. The polystyrene industry is in the process of find ing an alternative to HBCD jointly with flame retardant pro ducers . In April 201 1 Great Lakes Solutions announced investing in a facility to produce a brominated polymeric flame retardant suitable for EPS and XPS. Little is known about the environmental and health properties of these substances. 73. The HBCD industry h as highlighted the main challenges in the search for alternative flame retardants as the following (BSEF 2011):

a. Fire performance of the products with the flame retardant over the complete service life, which needs to meet existing stringent regulations in the relevant countries b. Fit to produce foams without undermining the foam properties. In addition, once found and approved for fire safety and other regulatory requirements, an alternative will have to be transitioned throughout the complex PS insulation f oam market c. Consumer safety for the end product, w hich needs to be similar to HBCD in PS foams d. Environmental profile, which needs to be superior to HBCD. Fit to produce foams without increasing safety risks for workers . 74. T here are also alternative insulatio n materials available on the market that meet the fire - safety requirements in many countries facilitating HBCD phase - out for this application . Alternative insulation materials to EPS/ XPS are available for all uses, with the exception of some demanding XPS use in mo ist or freeze/thaw sensitive applications in North America ( XPSA/CPIA 2011 ) . These alternative insulation systems have different characteristics to XPS and EPS**Persistent Organic Pollutants Review Committee**

14 and may be less appropriate for some specific use scenarios or may incorporate differe nt environmental issues such as increased energy costs during transportation (ECHA 2009). Alternatives to HBCD 75. B rominated chemicals other than HBCD are commercially available as flame retardant s for use in EPS applications in North America . These are tetrabromocyclooctane and dibromoethyldibromo - cyclohexane (LSCP 2006 , BSEF 2011 ) . There are also concerns about the environmental or health properties of these substances :  Tetrabromocyclooctane is structurally related to tetrabromocyclohexane which was identifi ed in mo delling studies as structurally similar to known Arctic contaminants and/or have partitioning properties that suggest that it is a potential Arctic contaminant.  Dibromoethyldibromo - cyclohexane is found in beluga whales in the Arctic; mo delling studies identify it as likely to be persistent and bioaccumulative ; and it was found to be a strong androgen agonist and mutagenic to mammalian cells in vitro. 76. The Japanese EPS industry is aiming at replacing HBCD in the production processes by the end of 20 12 and also the industry producing XPS is working towards reduction in HBCD use by reconsidering HBCD content but also the need for HBCD in the product (Japan 2011) . Interestingly, the European industry appears to use higher amounts of HBCD than North American producers to meet the fire safety requirements. 77. The first consideration would be to eliminate use of HBCD and other flame retardants in cases where no fire hazard exists. These uses include placement of insulation between two non - combustible wall surf aces such as stone or concrete and uses where insulation is placed between building foundations and soil. These design changes could be im plemented by the end - product manufacturer (LCSP 2006). 78. Another strategy would be to apply the flame retardancy function through the use of fire resistant coverings or coatings that act as thermal barriers. Thermal barriers are fire resistant coverings or coatings that separate the insulation material from the building interior. These include: gypsum board, gypsum or cement plasters, perlite board, spray applied cellulose, mineral fiber, or gypsum coatings, and select ed types of plywood. All these materials are currently in common use in domestic and commercial building construction (LCSP 2006, SWEREA 2010) . Thermal barri ers are subject to country - specific building code requirements (SWEREA 2010) . 79. By u sing thermal barriers it is possible to fulfil fire safety requirements in most of the uses in construction and buildings with EPS and XPS without a fire retardant . This has been reported to be an available alternative on the market by Finland, Norway, Sweden and Spain. The national fire safety requirements are achieved by the building codes specifying the different uses of insulation products in buildings and construction, through the use of thermal barriers and hence the use of flame retardant is not required to achieve fire safety even when using EPS/XPS. Alternatives to EPS/XPS 80. Flame retarded expanded and extruded polystyrene foam (EPS and XPS) used for building insulatio n can also be replaced by alternative materials . This is a more complex approach than simple flame retardant substitution because it has a greater effect on overall product cost and performance. This change could be implemented by the polymer processor/com

pounder or the end - product manufacturer (LCSP 2006). 81. Ty pes of alternative insulating materials include polyisocyanurate foams, and phenolic foams : a. Polyisocyanurate foams include modified urethane foams that utilize chemical flame retardants such as tris monochloropropyl phosphate (TCMPP) and tris chloroethyl phosphate (TCEP). TCMPP is poorly characterized toxicologically but in the TCEP manufacturing process ethylene oxide (a carcinogen) is used, it appears to be a reproductive toxicant , is found in the Ar ctic indicating long range transport , and is considered a carcinogen by the California Office of Environmental Health H azard Assessment. Due to the chlorinated and brominated flame retardants used in the manufacture of polyiso cyanurate insulation products , these cannot be considered to be preferable alternatives because of their health effects (LCSP 2006). b. Phenolic foams are in use in roofing, cavity board, external wall board, and floor insulation. They are mo stly used to bind glass fiber to make insulati on products. One concern over their use is that formaldehyde, a human carcinogen, is used for making phenolic resins monomer. Formaldehyde is listed by the International Agency for Research on Cancer (IARC) as a known human carcinogen (Morose 2006). This h as to be considered at the production sites, using available emission control techniques and safety restrictions securing the workers.**Persistent Organic Pollutants Review Committee**

15 c. Blanket insulation is as much a technical alternative as an alternative material. It is usually made of fiber glass or r ock wool and can be fitted between studs, joists, and beams. It is available in widths suited to standard spacings between wall studs or floor joists. Continuous rolls can be hand cut and trimmed to fit various spaces. The blankets are available with or wi thout vapour retardant facings. Batts with special flame resistant facing are available where the insulation will be left exposed. d. Fiberglass is a synthetic vitreous fiber. Loose - fill insulation is typically blown into place or spray applied by special equipment. It can be used to fill existing wall cavities and for irregularly shaped areas. e. Reflective insulation systems include foils, films, or papers that are fitted between studs, joists, and beams and commonly used to prevent downward heat flow in roof applications. Common materials include foil - faced paper, foil - faced polyethylene bubbles, foil - faced plastic film, and foil - faced cardboard. f. Other commonly used insulation materials include polyester batts and sheep wool which can be fitted between studs, joists, and beams. 82. Technical alternatives to HBCD containing EPS/ XPS include : blow n - in or spray - applied insulation materials such as rock wool, fiber glass, cellulose, or polyurethane foam. Loose - fill cellulose insulation is commonly manufactured from rec ycled newsprint, cardboard, or other forms of waste paper. The blown - in loose - fill insulation can provide additional resistance to air infiltration if the insulation is sufficiently dense. Loose - fill insulation can also be poured in place by using material s such as vermiculite or perlite. These materials are produced by expanding naturally occurring minerals in a furnace (LCSP 2006). 83. When alternative building insulation materials or EPS and XPS without flame retardants are used the necessary flame protectio n can be provided by use of a thermal barrier. Thermal barriers are fire resistant coverings or coatings that separate the insulation material from the building interior. Thermal barriers can be used to increase the fire retardant performance for various types of insulation. Thermal barriers are subject to current building code requirements. Commonly used thermal barriers include: gypsum board, gypsum or cement plasters, perlite board, spray - applied cellulose, mineral fiber, or gypsum coatings, and select p lywood’s. By using thermal barriers it is possible to fulfil fire safety requirements in most of the uses in construction and building applications using EPS and XPS without a flame retardant . This has been reported to be an available alternative on the market by Norway, Sweden and Spain (SWEREA 2010) . 84. Fiberglass, glass wool, and mineral wool are considered synthetic vitreous fibers. They also may have occupational health effects. When these fibers are suspended in air they can cause irritation of the eyes, nose, throat, and parts of the lung. Animal studies show that repeatedly breathing air containing synthetic vitreous fibers can lead to inflammation and fibrosis of the lung. ( AT SDR 2004 ). Protective clothing and equipment (face masks, goggles, gloves etc . ) is available and used by construction workers to avoid irritations from contact and breathing in the fibres . This will only be of importance in the working environment, since the fibrous material is built in side the wall, foundation and ceilings in the buildings and constructions . **2.4. Su**  **mmary of inform ation on impacts**  **on society of im** **plementing possible control measures** 85. As the persistent, bioaccumulative and toxic properties of HBCD as well as its potential for long - range transboundary transport were sh own in the risk profile agreed by the POPRC of the Stockholm Convention, a positive im pact on globally sustainable development from an elimination of HBCD is to be expected. If production and use of HBCD with persistent, bioaccumulative and toxic propertie s is not managed, and were to continue or increase, then levels in the environment including in humans and animals will likely continue to rise, even in locations distant from production and use . **2.4.1. Health, including public, environm**  **ental and occupatio nal health**  86. A positive impact on human health and on the environment can be expected from reduction or elimination control measures on HBCD on a global scale, especially in relation to blood levels . In humans HBCD is found in blood, plasma and adipose tissu e. The main sources of exposure presently known are contaminated food and dust. Imposing control measures would likely ensure that the levels of HBCD in agricultural products like farmed (and wild) fish, milk/milk products and various meat products level o ff. In the short term, the most positive effect would be anticipated to be on the indoor environment; with HBCD levels in dust being completely eliminated or dramatically reduced as a consequence of a ban . A positive outcome of this would be reduced exposure to humans, particularly children, who have been shown to ingest more dust than adults ( UNEP/POPS/POPRC.6/13/Add.2 ). 87. Though information on the human toxicity of HBCD is to a great extent lacking, embryos and infants have been identified as vulnerable gr oups that could be at risk ( UNEP/POPS/POPRC.6/13/Add.2 , RAC 2010 ) , particularly due to**Persistent Organic Pollutants Review Committee**

16 the observed neuroendocrine and developmental toxicity of HBCD observed in animal studies . Phase - out or elimination of HBCD wo uld also be particularly beneficial to Arctic indigenous peoples who depend on traditional native foods and therefore are at much greater risk of exposure than other communities. The particular risks posed by POPs to Arctic ecosystems and indigenous communities are acknowledged in the preamble to the Convention. 88. In developing countries, electrical and electronic appliances containing HBCD and other toxic substances are often recycle d under conditions which result in a relatively high release of HBCD to the environment and contamination of the sites ( Zhang et al., 2009 ), and exposure of workers ( Tue et al., 2010 ) . Open burning and dump sites are common destinations for HBCD - containing articles and electronic wastes ( Malarvannan et al., 2009, Polder et al., 2008 ). 89. HBCD and other brominated flame retar dants (BFRs) may also increase fire toxicity and lower surviv al by augmenting the release of carbon monoxide and soot and production of halogenated dibenzodioxins and dibenzofurans (see Dioxin ( 2010 ). T he prevalence of certain kinds of cancer in fire fight ers may be linked to an elevated exposure to brominated and chlorinated dioxins and furans and this warrants further attention. T he overall fire safety benefit of regulations requiring flame retardants has been questioned since they can increase the releas e of toxic gases and soot which are the cause of most fire deaths and injuries (DiGangi et al 2010, Stec & Hull 2010). C om bustion of materials containing HBCD or other halogenated flame retardants during accidental fires and burning flame - retarded waste in creases the toxicity of fire effluents by increasing the release of carbon monoxide, acid gases such as hydrogen bromide, and brominated and chlorinated dioxins and furans (Shaw et al 2010) . An overall reduction of flame - retarded materials may therefore l e ad to a smaller risk of health problems for the general public and fire fighters , if fire safety can be achieved by other means . **2.4. 2**  **Biota (biodiversity)** 90. A positive impact on biota from a ban of HBCD can be expected. The scientific literature has identified that HBCD is very toxic to aquatic organisms . In avian species, data from recent studies report effects such as reduced eggshell thickness, growth and survival. Further indications for concern come from recent preliminary data obtained with captive American kestrels which suggest a risk for reproductive and developmental effects also in wild birds in remote regions ( UNEP/POPS/POPRC.6/13/Add.2 ) . **2.4. 3**  **Economic aspects, including costs and benefits for producers and consumers and the distribution of c osts**  **and benefits** 91. The cost for developing countries of a phase out of HBCD uses should be limited , as the majority of the HBCD use takes place in Europe. A ccording to BSEF, a ban of HBCD in the absence of a drop - in alternative wo uld severely harm the EPS and XPS industry in Europe and drastically impact the economics also for non - HBCD containing PS foam. In addition , specialized waste management and disposal related to HBCD (buildings and articles) could be costly for both developed and developing countrie s . According to information from XPSA and CPIA a ban of HBCD would prevent the use of XPS products containing the substance, end the current practices of the XPS industry in the US and Canada, and cause difficulties since for many applications XPS is the o nly product recommended and accepted by current building code s . The recent progress in finding a polymeric chemical alternative, although brominated, may alleviate these concerns. 92. Emission reduction measures and use of best practices would be required in the production for potential specific exemptions and use therein to reduce HBCD releases to the environment from these uses. European HBCD and polystyrene manufacturers have in 2006 initiated emission reduction programmes, which are target ed at eliminating emissions from first line users of HBCD ( Self - Enforced Control of Use to Reduce Emissions ( SECURE ) and Voluntary Emissions Control Action Programme ( VECAP) ) . Most of the European PS foam industry implements those risk reduction measures (EBFRIP 2009a). Imp lementing best practices in handling reduced the total potential releases from 2,017 kg/year in 2008 to 309 kg/year in 2009 in the survey. The costs of emission reduction programmes initiated by European HBCD and polystyrene manufacturers are highly depend ent on the company operations (BSEF 2011) . Also the Japanese curtain and blind industry has developed a coagulation - sedimentation method in the dyeing process to reduce HBCD emissions to water (Japan 2011). 93. In accordance with Article 6(1)(d)(ii), HBCD cont aining products (EPS, XPS, HIPS, textiles) should be managed in an environmentally sound manner and disposed of in such a way that their POPs content is destroyed or irreversibly transformed so that they do not exhibit the characteristics of POPs . This wil l require separation of HBCD containing articles from others upon becoming waste and the prevention of inappropriate waste management practices leading to recycling of the POP content . 94. For drop - in chemical substitutes, two main types of costs have to be c onsidered concerning the switch from one flame retardant to another ( SWEREA 2010 );**Persistent Organic Pollutants Review Committee**

17 a. The switching cost, which is the cost of reformulation, in other words the cost of the development work or equipment change. Manufacturing and processing facilities may need to invest in new equipment in order to shift to alternative flame retardant s. This cost is difficult to estimate, and usually contains the cost of those research and development endeavours which did not succeed in finding an efficient flame retardant alte rnative. This is a cost which is generated at the beginning of a product life cycle. b. The operating cost which reflects the price of the flame retardant (raw) material cost. In addition, daily operation costs may be different for the ne w process steps requi red to manufacture other flame retardant chemicals. To ensure economic viability, flame retardants must be easy to process and cost effective for what most of the time high - volume manufacturing conditions are necessary. The cost s of manufacturing are heavi ly dependent on the costs of raw materials, but the degree of this dependency varies among the flame retardants . 95. Following this, the PS foam industry must adapt to the ne w flame retardant alternatives. In spite of those costs mentioned above, mo vement to alternatives already exist s im plying that the costs are acceptable and not critical , although not yet fully known . 96. A ban on HBCD can have consequences for EPS and XPS producers in relation to the workforce in this sector (Plastic s Europe /Exiba 2011, XPSA/ CPIA 2011 ). In 2003 the EPS sector group and the European XPS producers in Europe initiated projects to find alternatives to HBCD for use in EPS and XPS and to share the costs connected with the development of new alternatives with the flame retardant producers ( HBCD industry wo rking group 2009 ). At this time HBCD was undergoing risk assessment under the Existing Substance Regulation (EC) 793/93 in the EU, and the manufacturers of EPS and XPS were highly concerned about the outcome of the environmental prof iling, the future regulatory situation and the resulting impact on producers and users (HBCD Industry Working Group 2009). The HBCD industry wo rking group reported to the UNECE/CLRTAP process in 2010 that current estimations from the two projects underway were that an alternative w ould be available on the market in 5 - 10 years. This included the registration of the alternatives under REACH in the EU. 97. In North America the major brominated flame retardant manufacturers (Albemarle, Chemtura Corporation and ICL - IP) have formed alliances with other companies (forming the North American Flame Retardant Alliance (NAFRA) under the umbrella of ACC) to promote and defend a broad range of flame retardants. The three companies have inorganic phosphor based flame retardants in their portfolio in addition to the brominated flame retardants . Other brominated flame retardants for use in EPS are already on the United States market as alternatives to HBCD (LCSP 2006). They are however not applicable to the European industry which uses different processes for manufacture of EPS and XPS. However, the re is a recent announcement by Great Lakes Solutions on preparations to start production of a directly applicable alternative to HBCD . 98. EPS and XPS insulation boards are most often co vered by other materials in buildings and constructions. Using thermal barriers will not represent an extra cost, since thermal barriers used are common materials and relatively cheap. EPS and XPS without flame retardants are commercially and technical ly f easible alternatives today and do not represent a higher cost to the manufacturer. The market in Scandinavia is dominated by polystyrene boards without flame retardants. This is accomplished by fire safety regulations not requiring treatment with a flame r etardant, acquiring the same level of protection through other means and relies to a lesser extent on flame retardants ( SWEREA 2010 ). In this region , only producers manufacturing EPS and XPS for export, like in Norway, will be affected by a ban on HBCD. 99. Co nsequences for the elimination of HBCD through legislation will influence markets with a substantial production and use of HBCD flame retarded EPS insulation boards (Europe) , but to a lesser extent markets that are less dependent on HBCD due to use of othe r processes of EPS manufacture using other brominated flame retardants ( the US ). As there are currently no known chemical alternatives for XPS, HBCD elimination will affect production of flame retarded XPS in all regions , unless a suitable alternative can be phased in in a timely manner . The ongoing initiatives in the polystyrene foam sector to find alternatives for use of HBCD (North America and Europe) are accomplished by sharing the costs and investments in voluntary projects between the flame retardant producers and the polystyrene foam manufacturers (HBCD Industry working group 2009). For regions wh ere HBCD is largely phased out (Scandinavia) the cost will be low . Conclusively, the cost implications for producers are considered to be low to moderate, an d a switch to other flame retardants will stimulate some producers (KLIF 2010) . 100. Increase in cost for manufacturers of HIPS and textile coating s is expected to be low since substitutes are already in use. For the EU , the total incremental costs at the production level of replacing the HBCD in HIPS in all EEE have been estimated in the range of 1 - 10 million €/year if HBCD is replaced with other brominated flame retardants and 5 - 25 million €/year if the HIPS/HBCD is replaced by copolymers with non - halogenated flame retardants. The costs may decrease over the years as a result of a larger market for the alternatives (DEPA 2010) .**Persistent Organic Pollutants Review Committee**

18 101. In controlled burning of wa ste, the c ontrol measures and application of BAT/BEP to address other by - products from incineration reduce by - product emissions of HBCD and brominated dioxins and furans. There are no extra costs involved for the industry. 102. Flame - retardants that are either more expensive per kg or require more flame retardant per unit polymer mass (or volume) to meet the fire safety standards will increase the raw material costs. Large differences betwe en flame retardant chemicals ’ prices do not necessarily have any impact on relatively expensive end products (SWEREA 2010). When used as an additive in PS foams, HBCD total content by weight varies between 0.5% (EPS) and 2.0% (XPS) ( XPSA/CPIA 2011, CEFIC 2 011). 103. In several countries in the EU the fire safety requirements are performance based. HBCD or any other flame retardant are not required to fulfil the fire safety regulations, but if non - flame retarded EPS/XPS boards are used the fire - safety requirements call for structural applications where the fire - safety is achieved with non - combustible barrier material. In some countries lining of walls and roofs needs flame retarded polystyrene foam if used. Usually other insulation materials are used for this pur pose. In a few European countries only special applications require polystyrene foam to be treated with a hi gh performance flame retardant . In other countries retarded EPS and XPS is used due to storage and insurance reasons and not due to the fire safety regulations. Several countries have stringent fire safety requirements on the insulation boards themselves used in buildings and constructions and in those countries EPS and XPS have to be treated with a flame retardant such as HBCD. 104. For several countrie s the use of EPS and XPS without flame retardants will require an adjustment of policies and a change in the way of implementation of fire safety standards. This will take time , and costs are considered to be mo derate. In the EU there are already initiativ es to harmonize the fire safety regulation standards, and HBCD is on the indicative list of hazardous substances that should be avoided for use for fire protection in buildings and constructions. This would also be an important drive to change the fire regulations, from classifying the building materials as components of the construction elements, to classifying the construction elements themselves. (KLIF 2010). **2. 5**  **. Other**  **considerations** 105. For more information about industry innovations regarding HBCD alternatives please see the following websites : http://chemtura.investorhq.businesswire.com/press - relea se/company - news/chemtura - corporation - first - sign - license agreement - dow - chemical - company - po 106. The industry voluntary actions to reduce emissions of HBCD in Europe are described at:  http://www.bsef.com/our - substances/hbcd/voluntary - emissions - reduction - programme - vecap - and - secure  http://www.vecap.info/ 107. M ore information about product redesign and fire safety is avai lable at: www.sp.se/en/index/services/greenflame . The Green Flame  is a voluntary system for simultaneously assessing products, in relation to environment and health quality, when involved in fire s. It is open for all kinds of different products and will create incentives for manufacturers who design products that perform better than the standards applicable to them. The intention is that the Green Flame  system will provide competitive advantages to the companies that possess the competence and determination to develop consumer products that represent a major im provement in fire safety and environmental quality . 108. HBCD monitoring information is available from Europe, North America and Asia. To follo w the effectiveness of the potential actions, HBCD should be added to the existing POP monitoring activities. 

### 3. **Synthesis of information 3.1 Summ**  **ary of risk profile inform ation**  109. The commercially available brominated flame retardant hexabromocyclododecane ( HBCD) is lipophilic, has a high affinity to particulate matter and low w ater solubility. Depending on the manufacturer and the production method used, technical HBCD consists of 70 - 95 % γ - HBCD and 3 - 30 % of α - and β - HBCD. HBCD is used as a flame retardant additive in polystyrene and textile products. Its main use is in the production of expanded and extruded polystyrene (EPS and XPS). It is also used in the production of high impact polystyrene (HIPS) and as a textile coating. HBCD is reported to be produced in the United States of America, Europe, and Asia . Approximately half of the market volume is used in Europe. 110. In biota, HBCD has been found to bioconcentrate, bioaccumulate and to b iomagnify at higher trophic levels. High concentrations have been identified in Europe and Japan and in coastal waters of south China , near production**Persistent Organic Pollutants Review Committee**

19 sites of HBCD, manufacturing sites of products containing HBCD and waste disposal sites including those whose processes include either recycling, landfilling or incineration. 111. HBCD is persistent in the air and is subject to long - range transport. HBCD is found to be widespread in remote regions such as the Arctic, where concentrations in the atmosphere and top predators are elevated. 112. HBCD is very toxic to aquatic organisms. In mammals, studies have shown reproductive, developmental and behavioural effects. Recent advances in the knowledge of HBCD - induced toxicity includes a better understanding of the potential of HBCD to interfere with the hypothalamic - pituitary - thy roid (HPT) axis, its potential ability to disrupt normal development, and to affect the central nervous system. 113. In humans HBCD is found in blood, plasma and adipose tissue. Human breast milk data fr om the 1970s to 2000 show that HBCD levels have increased since HBCD was commercially introduced as a brominated flame retardant in the 1980s. **3. 2**  **Summ ary of risk**  **managem ent evaluation**  **inform ation**  114. HBCD is produced in China, Europe, Japan, and the USA. The known current annual production is approximately 23 , 000 t onnes per year (9,000 to 10,000 t onnes in China, 13,426 t onnes by the BSEF companies in Europe and the US , Japan not known ). T he main share of the market volume is used in Europe . HBCD has been on the world market since the 1960s. It is used as a flame retardant additive, wi th the intent of delaying ignition and slowing subsequent fire growth during the service life of vehicles, buildings or articles, as well as while materials are stored. The main u ses of HBCD globally are in flame - retarded expanded (EPS) and extruded (XPS) polystyrene foam insulation , while the use in textile applications and electric and electronic appliances (HIPS) is of a smaller scale . The use of HBCD in insulation boards starte d in the 1980s. In textiles HBCD is used in back - coating used for upholstery furniture and other interior textiles, including automotive applications. 115. A number of alternative fire retardants are available to replace HBCD in HIPS and textile back- coating. H owever, there are no drop - in chemical alternatives for certain flame - retarded EPS/XPS production. In some countries there is a need for flame retarded insulation materials due to the country - specific fire safety requirements. In some countries HBCD has eff

ectively already been phased out. In those countries the fire safety regulations do not require treatment with a flame retardant , and the same level of fire safety is achieved by other alternatives, that are technically feasible and also commercially avail able. HBCD phase - out could include flame retardant substitution, resin/material su bstitution and product redesign . Emissions of HBCD can be reduced in the processes where HBCD or articles containing HBCD are used, and during the waste management phase. 116. HBC D may be released to air, water, soil and sediment during all stages of its life cycle; production and manufacturing, processing, transportation, use, handling, storage or containment, point - source discharges, migratory releases from manufactured product u sage and from disposal of the substance or products containing the substance. European producers and manufacturers have successfully taken measures to reduce emissions from production and first line use. Emission control techniques at the production sites will not prevent HBCD emissions , since the re are diffuse emissions and releases to the water reserves and se wage systems from products containing HBCD during use or upon becoming waste . 117. HBCD is an intentionally produced industrial chemical. Under the Conv ention, the most adequate control measure is listing in Annex A. To allow for certain time - limited critical uses of HBCD , a specific exemption for use of HBCD could be given together with a description of the conditions for production and these uses . Waste s containing HBCD are a concern because they will represent a large source of releases and because increasing amounts of HBCD containing wastes in landfills and other locations could be a long - term source of HBCD emissions. Wastes containing HBCD include p roduction wastes, insulation boards, building and renovation wastes, and from other less - commonly used applications such as electrical and electronic products and textiles. The process of remodelling and demolition of buildings leads to concerns that insta lled building materials containing HBCD will continue emissions in the future , unless properly managed by future generations . Stockpiles and waste containing HBCD would be subject to the provisions in Article 6. **3. 3**  **Suggested risk ma**  **nagement m easures**  118. Listi ng HBCD in Annex A of the Convention would prohibit the manufacture, use, import and export of HBCD (except as allowed under the Convention for environmentally sound disposal) and could be linked with specific exemptions that specify deadlines for the eventual elimination of remaining HBCD manufacturing and use. Such listing could also be coupled to other decision s that would describe in more detail such uses of HBCD and appropriate conditions for their manufacturing and use. When assessing whether specific exem ptions would be appropriate, among other considerations identified in Annex F to the Convention, factors such as exposure; production volume; and societal costs and the ubiquitous contamination of humans, the environment and possible impact on future generations should be considered.**Persistent Organic Pollutants Review Committee**

20 119. The suggested control measure is that HBCD be listed in Annex A, with or without specific exemptions, and if with exemptions accom

panied with detail ed conditions for HBCD uses . 120. Listing of HBCD in Annex A would be consistent with the POPs properties of this intentionally produced substance. Such a listing would send a clear signal that production and use of HBCD must be phased out. Such a listing may have implications for countries in light of ongoing uses where alternative substances or alternative methods need to be phased in. Stockpiles and waste containing HBCD wo uld be subject to the provisions in Article 6. 

### 4. **Concluding statement**  121. Having decided that hexabromocyclododecane (HBCD) is likely, as a result of long - range env ironmental transport, to lead to significant adverse effects on human health and/or the environment such that global action is warranted; 122. Having prepared a risk management evaluation and considered the management options; 123. The Persistent Organic Pollutants Revie w Committee recommends , i n accordance with paragraph 9 of Article 8 of the Convention, the Conference of the Parties to the Stockholm Convention to consider listing and specifying the related control measures of h exabromocyclododecane and 1,2,5,6,9,10 - hexabromocyclododecane in Annex A as described above.**Persistent Organic Pollutants Review Committee**

21 

### References **Form ats for submitting inform**  **ation specified in Annex F of the Convention pursuant to Article 8 of the Stockholm Convention are available for review on the Stockholm**  **Convention website: www.pops.int/poprc**  Brazil 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Burundi 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Canada 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Colombia 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, March 2011. China 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Costa Rica 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Czech Republic 2011. Format for submitting pursuant to Article 8 of th e Stockholm Convention the information specified in Annex F of the Convention, January 2011. Ecuador 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Finland 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Germany 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information speci fied in Annex F of the Convention, January 2011. Japan 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, March 2011. Nigeria 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Norway 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Mauritius 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. Romania 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the informat ion specified in Annex F of the Convention, January 2011. Sweden 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. [BSEF] 2011. Bromine Science and Environmental Forum (BSEF). Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. PlasticsEurope/Exiba 2011. Format for submitting pursuant to Article 8 of the Stockholm Conventi on the information specified in Annex F of the Convention, January 2011. Instituto do Meio Ambiente (IMA) Brazil 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2 011. [XPSA/CPIA] Extruded Polystyrene Foam Association (XPSA) and Canadian Plast ics Industry Association (CPIA). Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011. [ IPEN] International POPs Elimination Network 2011. Format for submitting pursuant to Article 8 of the Stockholm Convention the information specified in Annex F of the Convention, January 2011.**Persistent Organic Pollutants Review Committee**

22 **Other references:** [APME] Asscociation of Plastics Manufacturers in Europe (APME), European Extruded Polystyrene Insulation Board Association (Exiba), European Isocyanate Producers Association (Isopa) ( no date). Co - combustion of Building Insulation Foams with Municipal Solida Waste. Summary report. Authors: Vehlow, J., Mark, F.E. 4 p. [ATSDR] Agency for Toxic Substances and Disease Registry 2004. Synthetic vitreous fibers. Division of Toxicology ToxFAQs . http://www.atsdr.cdc.gov/tfacts161.pdf [BFR] 2010. Brominated Fl ame Retardants in Products: Results of the Swiss Market Survey 2008. Authors: Bantelmann, E., Ammann, A., Näf, U., Tremp, J. Abstract at BFR 2010 conference. 4 p. [ BSEF ] (Bromine Science and Environmental Forum). About Hexabromocyclododecane (HBCD). 2006. http://www.bsef.com/our - substances/hbcd/about - hbcd/ (accessed January 2008).  BSEF ] Bromine Science and Environmental Forum. About Hexabromocyclododecane (HBCD). 2010. http://www.bsef.com/our - substances/hbcd/about - hbcd/ (accessed June 2010) . [BUWAL] Bundes amt für Umwelt, Wald und Landschaft 2004. Bromierte Flammschutzmittel in Kunststoffprodukten des Schweizer Marktes. Authors: Kuhn, E., Arnet, R., Känzig, A. and Frey, T. 53 p. [CEFIC/EFRA] European Chemical Industry Council . European Flame Retardants Assoc iation 2006. Flame Retardants Fact Sheet. Hexabromocyclododecane (HBCD). 3 p. http://www.cefic - efra.com/Objects/2/Files/HBCDFactsheet.pdf [DEPA] 2010. Inclusion of HBCDD, DEHP, BBP, DBP and additive use of TBBPA in annex IV of the Commission’s recast propo sal of the RoHS Directive, COWI A/S . Danish Ministry of Environment, Environmental Project No. 13172010 . Authors Maag J, Brandt K, Mikkelsen S, Lassen C. 87 p. DiGangi J, Blum A, Bergman A, de Wit CA, Lucas D, Mortimer D, Schecter A, Scheringer M, Shaw SD, Webster TF (2010) . San Antonio statement on brominated and chlorinated flame retardants, Environ Health Perspect 118:516 - 518 DIOXIN 2010. PBDEs and thei r replacements: Does the benefit justify the harm? Dioxin 2010, 1 - 6. Authors: Blum, A., S haw , S. & B i rnbaum , L. Desmet K, Schelfaut M, Sandra P. 2005. Determination of bromophenols as dioxin precursors in combustion gases of fire retarded extruded polystyrene by sorptive sampling - capillary gas chromatography - mass spectrometry. J Chromatogr ., A 1071(1 2): 125

– 129. Dumler R, Thoma H, Lenoir D, Hutzinger O. 1989. PBDF and PBDD from the combustion of bromine containing flame retarded polymers: a survey. Chemosphere 19(12):2023

–2031.  ECHA  European Chemicals Agency 2008a . Data on manufacture, import, export, u ses and releases of HBCDD as well as information on potential alternatives to its use. 108 pp [ ECHA ] ( European Chemicals Agency) 2008b . Member state committee support document for identification of hexabromocyclododecane and all major diastereoisomers as a subst ance of very high concern. 43 pp. Available at: http://echa.europa.eu/chem_data/authorisation_process/candidate_list_table_en.asp [ ECHA ] European Chemica ls Agency 2009 . Data on Manufacture, Import, Export Uses and Releases of HBCDD as well as Information on Potential Alternatives to Its Use. December 1, 2009. http://echa.europa.eu/doc/consultations/recommendations/tech_reports/tech_rep_hbcdd.pdf [EMPA] Swi ss Federal Laboratories for Materials Science and Technology 2010. RoHS substances in mixed plastics from Waste Electrical and Electronic Equipment. Final Report September 17, 2010. Authors: Wäger, P., Schluep , M. and Müller , E. 99 p. [Environment Canada]. Draft Screening Assessment Cyclododecane, 1,2,5,6,9,10 - hexabromo - Chemical Abstracts Service Registry Number 3194 - 55 - 6. Environment Canada. Health Canada. August 2010 a . 114 p. [Environment Canada]. Risk Management Scope for Cyclododecane,1,2,5,6,9,10

– hex abromo - (Hexabromocyclododecane; HBCD). Environment Canada. Health Canada. August 2010 b . 12 p. [ European Commission ] 2008. Risk assessment hexabromocyclododecane, CAS -No.: 25637 - 99 - 4, EINECS No.: 247 - 148 - 4, Final Report May 2008. 492 pp. http://ecb.jrc.ec. europa.eu/documents/Existing Chemicals/RISK_ASSESSMENT/REPORT/hbcddreport044.pdf [Geopartner] GEO Partner AG Resource Management 2007. Dynamic Substance Flow Analysis Model for Selected Brominated Flame Retardants as a Base for Decision Making on Risk Reduction Measures (FABRO). Final report. Authors: Morf, L., Buser, A., Taverna , R. 165 p.**Persistent Organic Pollutants Review Committee**

23 [HBCD Industry Working Group]. Update on research programmes on alternatives to HBCD for polystyrene insulation foams. Submission to ECHA public consultation (2009) and to UNECE (February 2010) 7 p. Heeb NV, Schweizer WB, Kohler M and Gerecke AC. Structure elucidation of hexabromocyclododecanes - a class of compounds with a complex stereochemistry. Chemosphere 2005; 61: 65 - 73. [KEMI] Swedish Chemicals Agency 2006. Surve y and technical assessment of alternatives to TBBPA and HBCDD. Author: Posner, S. [ KEMI ] Swedish ChemicalsAgency 2008. Proposal for Harmonised Classification and Labelling Based on the CLP Regulation (EC) No 1272/2008, Annex VI, Part 2. Substance Name: He xabromocyclododecan. Dossier submitted to the European Commission 2009; 49 pp. [KLIF] Climate and Pollution Agency in Norway . 2010. Exploration of management options for Hexabromocyclododecane (HBCD) . 18 August 2010 (updated version) . Author: Säll, L. 48 p . Heeb NV, Schweizer WB, Kohler M and Gerecke AC. Structure elucidation of hexabromocyclododecanes - a class of compounds with a complex stereochemistry. Chemosphere 2005; 61: 65 - 73.  INE - SEMARNAT  Instituto Nacional de Ecología, Secretaría de Medio Ambie nte y Recursos Naturales. Las sustancias tóxicas persistentes en Mexico. Report. Authors: Bremauntz AF,Yarto Ramírez MY, Díaz JC. 2004, 261 pp. [LCSP] Lo we ll Ce nter For Sustainable Production. An Overview of Alternatives to Tetrabromobisphenol A (TBBPA) an d Hexabromocyclododecane (HBCD). Report prepared for The Jennifer Altman Foundation. University of Massachusetts , 2006. Author: Morose G. 32 pp. [NCM] Nordic Council of Ministers. Emission measurements during incineration of waste containing bromine TemaN ord . Nordic Council of Ministers 2004:529 0903 - 7004 Corporate Author: Nordic Council of Ministers . 55 p. [NCM] Nordic Council of Ministers. Hexabromocyclododecane as a possible global POP. Nordic Chemicals Group and Nordic Council of Ministers , Author: Pel tola - Thies J. 2008, 91 pp. http://www.norden.org/en/publications/publications/2008 - 520 Malarvannan, G., Kunisue, T., Isobe, T., Sudaryanto, A., Takahashi, S., Prudente, M., Subramanian, A. & Tanabe, S. 2009. Organohalogen compounds in human breast milk fr om mothers living in Payatas and Malate, the Philippines: levels, accumulation kinetics and infant health risk. Environ Pollut, 157, 1924 - 32.  OECD  Organization for Economic Co - operation and Development. SIDS Initial Assessment Profile for Cas. No. 25637 - 99 - 4, 3194 - 55 - 6, Hexabromocyclododecane (HBCDD). SIAM 24, 19 - 20 April 2007. Available from: http://webnet.oecd.org/Hpv/UI/handler.axd?id=ea58ac11 - e090 - 4b24 - b281 - 200ae351686c Polder, A., Venter, B., Skaare, J. U. & Bouwman, H. 2008. Polybrominated diphenyl ethers and HBCD in bird eggs of South Africa. Chemosphere, 73, 148 - 154.  RAC ] Committee for Risk Assessment RAC. Opinion proposing harmonised classification an d labeling at Community level of hexabromocyclododecane (HBCDD). European Chemicals Agency (ECHA), 2010  RAC ] Committee for Risk Assessment RAC. Annex 1 . Background Document to the Opinion proposing harmonized classification and labelling at Community leve l of Hexabromocyclododecane (HBCDD). European Chemicals Agency (ECHA), 2010 . [Stec A & Hull R.] Fire toxicity.Woodhead publishing Limited, Oxford. 728 p. ISBN 1 84569 502 X Shaw SD, Blum A, Weber R, Kurunthachalam K, Rich D, Lucas D, Koshland CP, Dobraca D, Hanson S, Birnbaum L (2010) Halogenated flame retardants: Do the fire safety benefits justify the risks? Revie ws on Environ Health 25:261 - 305 [S WEREA ] Exploration of management options for HBCDD. Report. Authors: Posner S, Roos S , Ols son E . 2010. 84 pp. T ue , N. M., S udaryanto , A., T u , B. M., I sobe , T ., T akahashi , S., P ham H. V. & T anabe , S. 2010. Accumulation of polychlorinated biphenyls and brominated flame retardants in breast milk from women living in Vietnamese e - waste recycling sites. Science of The Total Environment, 408, 2155 - 2162.  US EPA  US Environmental Protection Agency. Initial Risk- Based Prioritization of High Production Volume Chemicals. Chemical/Category: Hexabromocyclododecane (HBCD). Risk - Based Prioritization Document 3/18/2008 Weil E .D. , Levchik, S.V. 2008. Flame Retardants in Commercial Use or Development for Textiles . Journal of Fire Sciences May 2008 vol. 26 no. 3 243 - 281**Persistent Organic Pollutants Review Committee**

24 Weber R, Kuch B. 2003. Relevance of BFRs and thermal conditions on the formation pathways of brominated and bro mi nated - chlorinated dibenzodioxins and dibenzofurans. Environment International 29: 699 - 710. Zhang, X. L., Yang, F. X., Luo, C. H., Wen, S., Zhang, X. & Xu, Y. 2009. Bioaccumulative characteristics of hexabromocyclododecanes in freshwater species from an electronic waste recycling area in China. Chemosphere, 76, 1572 - 1578.